No Special Appeal Against Art. 227 Order on Lok Adalat Award

No Intra-Court Appeal Against Article 227 Order Quashing Permanent Lok Adalat Award: Rajasthan High Court

Published: 29 October 2026 · NyayVidhan

A Division Bench of the Rajasthan High Court headed by the Chief Justice dismissed at the threshold an intra-court appeal against a Single Judge's order quashing a Permanent Lok Adalat award (paras 1, 5). The State had challenged the award under the High Court's supervisory jurisdiction under Article 227 of the Constitution. An intra-court appeal against such an order is not maintainable, the Bench held, and the appellant has an alternative efficacious remedy in accordance with law (para 4).

Key holdings

An intra-court appeal does not lie against a Single Judge's order made under Article 227 of the Constitution; the special appeal was dismissed at the threshold (paras 4-5).

Under Section 21 of the Legal Services Authorities Act, 1987, a Lok Adalat award is deemed a civil court's decree, final and binding, and no appeal lies against it (para 3).

The Single Judge's reasons for quashing the award, including that the Lok Adalat ventured into disputed questions of fact in a contractual insurance dispute, were found cogent (para 3).

Ratna @ Ratan Lal v. Board of Revenue (D.B. Civil Special Appeal (Writ) No. 756/2022) was held distinguishable (para 4).

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Brief Facts

The appellant obtained an award dated 23 July 2018 from the Permanent Lok Adalat, Jaipur Metropolitan, in Case No. 154/2016, directing the release of payment and bonus that had not been released to him (paras 1, 3). The State of Rajasthan, through its Finance Department, and the Joint Director (Insurance), State Insurance and Provident Fund Department, challenged the award in S.B. Civil Writ Petition No. 13114/2019 (para 1). On 19 January 2026 a Single Judge allowed the petition and quashed the award (paras 1, 3). The appellant filed a special appeal, relying on the Division Bench decision in Ratna @ Ratan Lal v. Board of Revenue (para 4). The Bench heard his counsel (para 2).

Court's Findings

The Bench recorded that the dispute concerned the non-release of payment and bonus, which the Permanent Lok Adalat had directed (para 3). It found that the Single Judge had quashed the award for ‘cogent reasons’ (para 3). Among them: a Permanent Lok Adalat is established under Section 22B(1) of the Legal Services Authorities Act, 1987 and governed mainly by Sections 22C and 22D; it must first try to settle a dispute by negotiation or conciliation and has power to decide it if no settlement is reached; the Lok Adalat had ventured into disputed questions of fact; and the dispute admittedly concerned insurance, a contractual obligation, with no acceptance by the respondents (para 3). The Bench added that under Section 21 a Lok Adalat award is deemed a civil court's decree, is final and binding, and is not open to appeal (para 3). Because the State had invoked the supervisory jurisdiction under Article 227, an intra-court appeal was not maintainable, and the appellant has an alternative efficacious remedy in accordance with law (para 4). Ratna @ Ratan Lal stood on a distinguishable footing and had no application (para 4).

Legal Principle

A Single Judge's order made in the exercise of supervisory jurisdiction under Article 227 of the Constitution, here quashing a Permanent Lok Adalat award under the Legal Services Authorities Act, 1987, is not open to an intra-court appeal before a Division Bench; the aggrieved party must pursue the alternative remedy available in law (para 4).

NyayVidhan's view · Practice note

Why It Matters

Before filing a special appeal against a Single Judge's writ order, check which jurisdiction the Single Judge exercised. Here the State had challenged a Permanent Lok Adalat award under Article 227, and the Division Bench held that an intra-court appeal against the resulting order was not maintainable, dismissing it at the threshold (paras 4-5). An award-holder who loses such a challenge must take a different route: the Bench said the appellant has an alternative efficacious remedy in accordance with law, but did not name it (para 4). Contrast R. Saravanan, where the Supreme Court dealt with an intra-court appeal against a writ court's decision under Article 226 and confined interference to demonstrably erroneous findings.

Editorial comment by the NyayVidhan Editorial Desk. It is not part of the Court's judgment and is not legal advice.

Precedents Relied Upon

Ratna @ Ratan Lal v. Board of Revenue D.B. Civil Special Appeal (Writ) No. 756/2022
Distinguished Discussed at ¶ 4
Division Bench decision relied upon for the appellant. The Court held that it stands on a distinguishable footing and has no applicability to the facts and circumstances of the present case; the judgment does not state what that decision held (para 4).